Does Your Internship Program Need a Mid-Term Tune Up?
Internships are a great way for companies to a) give learning opportunities to students aspiring to get into the music business, b) afford mentoring experiences to current employees, and c) build a pipeline of potential job candidates for future hiring needs. Even if your internship is well intentioned and running smoothly, now is the time to take a few simple steps to protect your company from misunderstandings and legal risk.
In recent years, Conde Nast, NBCUniversal, Viacom and Warner Music Group each paid settlements between $4M to $7M over complaints from former interns. If you run a company that uses interns, monitoring your program’s policies and practices each semester can prevent costly mis-steps. The points and resources below will help you support your interns’ classroom goals, and keep you out of the courtroom.
Compliance with the Department of Labor’s “Test for Unpaid Interns” is essential for any business that wants to do the right thing. Here are a few highlights from the test:
- Training in internships must be similar to what is given in educational environment. This requirement is best met when the intern is enrolled in a degree program and the duties of the internship meet credit requirements of the college or university.
- Internship must benefit the intern. A good way to ensure this is by maintaining coordination with a representative from the intern’s school, and ensuring that the intern’s supervisor documents their work and provides any data or reports that the school requests.
- The intern should not displace other employees.
The fall semester for most colleges ends in mid December. That means you have just a couple weeks left to tune up your internship policies and make sure that your current interns are gaining a learning experience that meets the legal requirements. This is especially important to review if your interns are unpaid.
James Celentano is a managing partner at business and employment advisory firm EnterGain, is on the adjunct faculty at NYU’s masters in music business program and is an associate member of A2IM. James can be reached at [email protected].